UNITED STATES DISTRICT COURT
DISTRICT OF VERMONT
VERIFIED COMPLAINT AND DEMAND FOR TRIAL BY JURY
Plaintiff, Nancy M. Haynes, by her attorneys Gravel & Shea PC, complains of Defendant
and alleges as follows:
Nature of Action
1. This is a civil action brought by Nancy M. Haynes (“Ms. Haynes” or “Plaintiff’)
for the recovery of compensatory and exemplary damages for injuries suffered as a result of
childhood sexual abuse as that term is defined in 12 VS.A. § 522(c) (“Sexual Abuse”).
2. Plaintiff was a child under the age of 16 during the years of sexual abuse alleged
in this Complaint. She is a citizen of the State of Vermont.
3. Defendant Sean A. Haggerty (“Mr. Haggerty” or “Defendant”) is a citizen of the
State of Virginia. At the time of the events alleged in this complaint, Mr. Haggerty went by the
name of Sue Haggerty and identified as a woman. Sue Haggerty legally changed her name to
Sean Haggerty in 2007 and began identifying as a man. For the purposes of this and other
motions, Plaintiff will refer to Defendant using male pronouns.
4. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a), there
being in excess of $75,000, exclusive of interest and costs, in controversy and this action being
between citizens of different states.
5. Plaintiff was born in March 1957.
6. Defendant was born in July 1942.
7. From 1971 through 1973, Defendant repeatedly committed acts of childhood
sexual abuse against Plaintiff in multiple states, including in Vermont.
8. Defendant admitted orally and in writing to sexually assaulting Plaintiff when she
was under the age of 16 years old.
9. In a police interview dated December 26, 1986, Defendant admitted to sexual
contact with Plaintiff when Plaintiff was 14 years old.
10. The childhood sexual abuse violated Vermont statutes which prohibited lewd or
lascivious conduct with a child (13 VS.A. § 2602), sexual assault (13 VS.A. § 3252) and
aggravated sexual assault (13 VS.A. § 3253) as they existed at the time of the conduct and
11. The conduct of Defendant constitutes outrageous conduct, done intentionally or
with reckless disregard of the probability of causing emotional distress.
12. Defendant’s outrageous conduct proximately or actually caused Plaintiff to suffer
extreme emotional distress.
13. As a direct result of the conduct alleged in this Complaint, Plaintiff has suffered
and will continue to suffer severe pain, emotional distress, embarrassment, humiliation, loss of
self-esteem, post-traumatic stress disorder and other psychological injuries; was prevented and
will continue to be prevented from performing her normal daily activities and obtaining the full
enjoyment of life.
14. Defendant engaged in wrongful conduct toward Plaintiff and in so doing acted
with bad motive, personal ill will, personal spite, hatred and reckless disregard for Plaintiff.
15. Defendant acted with evident insult and oppression toward Plaintiff and engaged
in actions against her having the character of outrage frequently associated with a crime and in
fact committed actual crimes.
16. Defendant’s conduct was reprehensible, egregious and patently outrageous.
Claims for Relief
WHEREFORE, Plaintiff respectfully requests that the Court award her compensatory and
exemplary damages against Defendant in an amount exceeding $75,000, the minimum
jurisdictional amount of this Court, together with interest, costs and such other relief as may be
available to her.
Plaintiff demands trial by jury of all issues so triable.
COMMONWEAL TH OF VIRGINIA
COUNTY OF CULPEPER, SS.
I, Nancy M. Haynes, being duly sworn, depose and say that I am the Plaintiff in the
within action; that I have read the foregoing Verified Complaint and Demand for Trial by Jury
and know the contents thereof as it relates to me personally; that the same is true to my own
Nancy M Haynes
NOTE: According to Nancy Haynes, the complaint contains an error. On page 2, under Fact #9, the date should state 1989, not 1986.
Sean Haggerty settled the lawsuit with his victim, according to court documents which state:
“Defendant Sean Haggerty, formerly known as Susan Haggerty (DOB July 1942), acknowledges engaging in sexual contact with plaintiff Nancy Haynes when Defendant Haggerty was a 29-year old woman and plaintiff Nancy Haynes (DOB March 1957) was 15 years of age. The sexual contact continued for several years. Defendant Haggerty was Nancy’s riding instructor and camp counselor and later her employer.
This statement is being made in connection with the full settlement of a lawsuit pending between Mr. Haggerty and Ms. Haynes.”